University of Cape Town. Ethics in Research. A handbook published by the Ethics in Research Committee (EiRC) of the Faculty of Commerce Ver. 4.

University of Cape Town Ethics in Research A handbook published by the Ethics in Research Committee (EiRC) of the Faculty of Commerce Ver. 4.0 Policy on Research Ethics Policy on Research Misconduct Ethics Review Process Policy on Plagiarism Authorship Guidelines Last updated January 2018 Adapted in part from the UCT Law & EBE Faculty Research Policies Handbook

Enquiries and Contact Information 1. Questions regarding the procedures of the application process may be directed to the Administrator of the Commerce EiRC, Mr Litha Tyulu, litha.tyulu@uct.ac.za; Tel (021) 650 2695. 2. Questions regarding the substance of applications should be addressed with departmental representatives of the EiRC or with the Chair of the Commerce EiRC, Prof Ulrike Rivett, ulrike.rivett@uct.ac.za or Tel. (021) 650 4213. 3. A list of Departmental Ethics in Research Representatives can be found here: http://www.commerce.uct.ac.za/pages/ethics-in-research 2 P age

CONTENTS 1 Research Ethics... 6 1.1 Ethics clearance procedures... 6 1.1.1 Exemptions... 8 1.1.2 Research in Organisations... 8 1.1.3 Research outside of South Africa... 8 1.1.4 Expedited Reviews... 8 1.1.5 Undergraduate research... 8 1.1.6 Master and PhD students... 9 1.1.7 Enquiries... 9 1.1.8 Contract research... 9 1.2 Application procedure and time lines... 9 2 Research Ethics Policy and Guidelines... 11 2.1 Faculty of Commerce Ethics in Research Policy... 11 2.2 Commerce Ethics in Research Guidelines... 12 3 Application for Ethics Clearance... 14 4 Exemplar of Informed Consent Document... 16 5 Ethics in Research FAQs... 17 5.1 Administrative matters... 17 5.1.1 Clearance from more than one EiRC?... 17 5.1.2 Do students academic research projects require EiRC approval?... 17 5.1.3 What is expedited review?... 17 5.1.4 Eligibility for exemption from review?... 17 5.1.5 Ethics review application process is so onerous.... 18 5.1.6 What is the role of the EiRC s?... 18 5.1.7 Where do I get the EiR application forms?... 18 5.1.8 Why is ethics clearance necessary?... 18 5.1.9 What about research in other countries?... 19 5.1.10 What about research in other organisations?... 19 5.1.11 My research changed - do I need to reapply for ethical clearance?... 19 5.1.12 Human Sciences Research Council website... 19 5.2 Substantive matters... 19 5.2.1 What is minimal harm?... 19 5.2.2 Access to government departments or NGOs?... 19 5.2.3 Can EiR ethics approval be shared with colleagues working on similar projects?... 20 5.2.4 Can student research involve collecting personal data from other students?... 20 5.2.5 What is deceptive research?... 20 5.2.6 Covert research... 20 5.2.7 Ethnographic research... 20 5.2.8 Is ethics clearance required if the research only involves counting students at lunch time on Jammie steps?... 21 5.2.9 Preliminary work or pilot study... 21 5.2.10 Publication of research findings... 21 5.2.11 Use of UCT students or staff members as participants?... 22 5.2.12 What constitutes research?... 22 5.2.13 What is risk of harm?... 22 3 P age

5.3 Ethical Matters... 22 5.3.1 Conflict of interest within the EiRC... 22 5.3.2 Filming or recording... 23 5.3.3 How does confidentiality differ from anonymity?... 23 5.3.4 Informed consent... 25 5.3.5 Mandatory reporting obligations for researchers... 25 5.3.6 Minors in research... 26 5.3.7 Raising concerns... 26 5.3.8 What happens if unexpected problems arise during the research?... 26 5.3.9 Who must report problems in the course of the research?... 26 6 Responsible Research Conduct... 26 6.1 Authorship guidelines... 27 6.1.1 Definition of a publication... 27 6.1.2 Authorship and Co-Authorship... 27 6.1.3 Authorship Agreement... 27 6.1.4 Student Staff-Supervisor Co-Publication... 27 6.1.5 Exclusions... 27 6.1.6 Acknowledgement of contribution to a research product... 28 6.1.7 Disputes... 28 6.2 Plagiarism guidelines... 28 6.3 Ethical and Scholarly Misconduct Regarding Research... 28 6.4 Conflict of interest... 28 7 Commerce Ethics in Research Committee... 29 7.1 Composition... 29 7.2 Terms of Reference... 29 8 Appendix... 32 8.1 Commerce Faculty Ethics in Research Policy... 32 8.2 UCT AUTHORSHIP PRACTICES POLICY... 34 8.3 UCT DRAFT COMMERCE POLICY AND PROCEDURES FOR BREACH OF RESEARCH ETHICS CODES AND ALLEGATIONS OF MISCONDUCT IN RESEARCH... 40 4.1 Overview of Procedures for a Complainant... 42 4 P age

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1 RESEARCH ETHICS 1.1 Ethics clearance procedures All research that involves the collection of data from or about living people must undergo ethics review (see Chapter 6) prior to any data collection taking place. The Faculty s Ethics in Research Committee is responsible for assisting researchers, including students, to ensure that their proposed research meets the highest ethical standards. As a general guide, if a researcher answers Yes to any of the questions below, ethics clearance has to be sought: 1. Is your research making use of human participants as a source of data? (You are using questionnaires, surveys, interviews, secondary data about people) 2. Is there a possibility that your research could cause harm to a third party? 3. Does your research involve the participation of communities? 4. Is your research providing a service to a community? 5. Is there a potential conflict of interest? 6. Is your research in the field of Health? NB: The Ethics Committee is not able to grant retrospective ethics clearance and retrospective applications will therefore not be considered. Any such application will be handed over to the Dean for review. Retrospective Ethics Clearance Please see below an overview of the considerations for an ethics applications: Important to note: The process highlighted below applies only if data is collected for the purpose of research as per the UCT definition of reseach: Research is defined as a systematic investigation designed to develop or to contribute to generalisable knowledge and conducted by means of surveys, interviews, focus groups, ethnographic observations, record reviews, etc. Should data be collected for any other purpose please refer to Chapter 1.1.1 6 P age

UCT FACULTY OF COMMERCE ETHICS CONSIDERATION FACTORS/QUESTIONS START NO Is Data Collected for the Purpose of Research? YES Are Humans a Primary or Secondary Source of Data? YES NO Ethics Application Data Research Could Cause Harm to a Third Party? YES NO Research Proposal Research Involves the Participation of Communities? NO YES Prepare Ethics Approval Information Pack Questionnaires, Surveys, Topic Guides ETHICS APPLICATION PROCESS Research Provides a Service to a Community? YES NO Consent Form There May be a Potential Conflict of Interest? NO YES Signature of Supervisor Research is in the Field of Health YES NO ETHICS Approval NOT Required 7 P age

1.1.1 Exemptions Some research that utilises human participant data may not require ethics clearance; it may be exempt from ethics review. Refer to Chapter 7 Ethics in Research FAQs Eligibility for exemption from review? or consult with the Chair of the EiR Committee. Research as part of an assignment in a course In the case of courses where students do research as part of an assignment, it should be established if the collection of information is 1) not done to develop or to contribute to generalisable knowledge ; and 2) the output is an assignment/report written solely for the eyes of the lecturer, and which is marked as an assignment/learning assessment. Exemptions Research as an assignment The assignment does not lead to a research output i.e. publication in the public domain. On these points it would not constitute research per se. Therefore ethics clearance would not be required. However, if the information will be included in a publication, which will be in the public domain or such, ethics approval is required. 1.1.2 Research in Organisations Research in organisations (global or local), which involves human participation may require in-organisation approval. It is the sole responsibility of the researcher to ensure that all requirements regarding the permission to interview staff have been fulfilled prior to any surveys being conducted. Permission of an organisation should be submitted as part of the application to the Commerce EiRC. 1.1.3 Research outside of South Africa Research in other countries, which involves human participation may require in addition to the approval from the Commerce EiRC, in country approval. It is the sole responsibility of researchers working in foreign jurisdictions to acquaint themselves with local standards, laws, regulations and best practices. In-country permission of an organisation should be submitted as part of the application to the Commerce EiRC. Refer to 5.1.9 International Research. 1.1.4 Expedited Reviews Sometimes an application for ethics clearance may be expedited, i.e. dealt with outside of the usual meeting schedule. Refer to Chapter 5 Ethics in Research FAQs What is expedited review? 1.1.5 Undergraduate research The departmental EiRC representative (as the HOD s nominee) is the final authority for providing ethics clearance for all undergraduate research in a department including Honours or Final Year capstone projects. The departmental EiRC representative will only consider an application once the supervisor of the undergraduate student has signed it off. Supervisors should understand that signing off an application for ethics clearance indicates taking responsibility for supervising the student in compiling the content of the application. It is critical that a student considers all of the items discussed in Chapter 3 of this document. Research in organisations/ companies Research outside South Africa Expedited Review Undergraduate and Honours Research 8 P age

1.1.6 Master and PhD students Master students whose research projects are 90 credits or less submit their application directly to their departmental EiRC representative for approval. Master students who have a research component with more than 90 credits and PhD students submit their application directly to the Faculty EiRC. 1.1.7 Enquiries Questions regarding the procedures of the application process may be directed to the administrator of the Commerce EiRC. Questions regarding the substance of applications should be addressed to supervisors in the first instance if the applicant is a student. Otherwise, such questions may be directed to the Chair of the Faculty EiRC. 1.1.8 Contract research Researchers who tender for contract research should note that the application for ethics clearance should be submitted at the same time that the tender is submitted. This practice serves to expedite matters so that unnecessary delays can be avoided. Master & PhD Students Enquiries Contract Research 1.2 Application procedure and time lines (a) Applications are submitted online (in electronic format) https://universityofcapetown.submittable.com/submit. (b) Applications will be checked for completeness and distributed to EiRC members electronically. Incomplete applications will be returned to the applicant for completion and resubmission. (c) Complete applications will be considered by the EiRC committee. Feedback will be provided within 15 working days after submission. (d) Applicants will be advised by email of the Committee s decision. (e) Applications that need to be revised and re-submitted will be put back into the queue of application, i.e. it may take 15 working days to review the revised application. If only minor corrections are required, the Committee will attempt to review the application sooner. The general requirements for the ethics clearance process include the submission of: Application Procedure and Timeline a completed application form (online system) a research proposal which must address issues raised in Chapter 3 of this document. This will include details of methods to be used, and a statement explaining how data or sensitive information will be safely secured. The research proposal may not exceed 15 pages. A copy of the questionnaire, survey or topic guide to be used in the research. The consent forms required permission from relevant authorities Please see below an overview of the Ethics in Research Process: 9 P age

UCT FACULTY OF COMMERCE - ETHICS APPLICATION PROCESS Applicant Administration & Committee START Submit Application to Animal Ethics Committee YES Use of Animals? Faculty Ethics Application Database Check Completeness of Application Submit Application to Health Sciences EiRC YES YES NO Health Related Research? NO Student? Notification of Incomplete Application Notification of Application in Review YES Application Incomplete? NO Send Notification that Application Received and in Review Research Less Than 90 Credits NO DIFFERENT ETHICS PROCESS REQUIRED Assign to Faculty Committee Member/s for Review YES Submit Application to Department Ethics Process NO Online Submission or Amendment of Faculty Ethics Approval Notification of Appropriate Ethics Committee Faculty Ethics Application Database YES Faculty Ethics Review Process Different Ethics Approval Required? YES Resubmit Application? Notification of Changes Required NO NO UNSUCCESSFUL APPLICATION Faculty Ethics Application Database YES Changes Required? NO APPROVED Faculty Ethics Application Faculty Ethics Application Database Draft Approval Notification Phase SUCCESSFUL APPLICATION 10 P age

2 RESEARCH ETHICS POLICY AND GUIDELINES Important: All research that will involve the collection of data from human participants must be submitted for review to the Commerce EiRC. Minor dissertations (less or equal to 90 credits) are approved within departments and do not get assessed by the Faculty. Exemptions are studies that would be classified as high risk or health research. Such studies have to be approved by the Commerce EiRC. Departmental EiRC representatives (as the HOD s nominee) are the final authority for providing ethics clearance for all undergraduate research in departments. The role of the EiRC is to guide and educate. No retrospective ethics clearances will be granted. Expedited reviews may be considered. Policy is used here to indicate the system of administration of research ethics in the Faculty of Commerce, while Guidelines means the procedures that should be followed and the matters that require consideration when making application for ethics clearance. This part of the handbook is to be read in conjunction with the UCT Research Ethics Code for Research Involving Human Participants, refer to http://www.uct.ac.za/about/policies/, and Chapter 7 of this document, Ethics in Research FAQs. 2.1 Faculty of Commerce Ethics in Research Policy All research conducted in the Faculty of Commerce - that is, all research conducted by Faculty staff which appears in association with their UCT affiliation, and all research conducted for academic credit by Faculty of Commerce students where human beings are participants, must be approved by the Commerce EiRC at Faculty or departmental level. The principal researcher has primary responsibility for ensuring that participants well-being is considered and safeguarded. In the case of a student researcher, the supervisor is expected to provide guidance. All others involved in the project share this responsibility. Applications for ethics clearance should address all the matters stipulated in the application form so that the EiRC is able to understand clearly what is proposed and how it will be achieved. The primary role of the Commerce EiRC is educative rather than policing, flowing from the EiRC s responsibility for assisting and supporting researchers, including students, to ensure that their proposed research meets the highest ethical standards. The EiRC is authorised to review research proposals, to suggest or require amendments, and to decide whether to grant ethics clearance, in accordance with the policy outlined here, the UCT Code for Research involving Human Participants (see http://www.uct.ac.za/about/policies/) 11 P age Role of EiRC

and in accordance with the Ethics Guidelines of the Faculty of Commerce. The EiRC may consult with others who are especially qualified to represent the views of a participant population. The departmental EiRC representative (as the HOD s nominee) is the final authority for providing ethics clearance for all undergraduate research in a department. Members of the EiRC must not participate in the review of projects in which they are involved or have a conflicting interest. Members are expected to provide insight into proposals from their respective Department if they are not directly involved in that research. The EiRC considers applications weekly for ethics clearance and meets quarterly to discuss related matters. Internal reviews Conflict of interest 2.2 Commerce Ethics in Research Guidelines All research conducted in or under the auspices of the Faculty of Commerce that proposes to involve the collection of data from human participants must be submitted for review to the EiRC, a subcommittee of the Faculty Board. No research may begin unless clearance has been granted by the EiRC. Sometimes more than one EiRC must review research proposals. For example, if research is intended with hospital or clinic patients, then the proposal must be submitted to the Health Sciences Faculty EiRC as well as to the EiRC of the Faculty of Commerce. This is because the Health Sciences Faculty has primary responsibility for hospital and clinic patients (inpatients and outpatients). It must consider, amongst other things, whether particular patients (e.g. HIV positive patients) may be overresearched, i.e. burdened by frequent requests for research participation. Applications may be submitted simultaneously and should so state. Pilot research, i.e. preliminary work done towards establishing the feasibility of a more developed research project may not require ethics clearance. However, prudence dictates that some discussion with a member of the EiRC may take place to ensure that pilot data collection is not jeopardised in the event that such data is to be used later. The final authority for providing ethics clearance for undergraduate students is devolved by the EiRC to the HOD who in turn delegates the responsibility to the departmental EiRC representative. No retrospective ethics applications will be considered or ethics clearances granted by the Commerce EiRC unless instructed by the Dean. In line with UCT General Rule G17.1 1, appeals for retrospective clearances have to be made to the Faculty Manager, who will then forward them to the Dean for consideration. If the appeal is successful, the Commerce EiRC at the instruction of the Dean will assess the application as described in PART I of this document. An application will be treated as being retrospective if: Involvement of other EiRCs Pilot Studies Retrospective clearances 1 Rule G17.1: Where these rules allow discretion, the decision to exercise the discretion lies with Senate. In these cases, and in cases not provided for in the rules, Senate s authority may be exercised under delegated authority, by deans and other officers, or by faculty boards or other committees A student may appeal against a decision affecting him or her made on behalf of Senate by a dean or other officer, or by a Faculty board or other committee. This rule can be found in the UCT General Rules and Policies Handbook. 12 P age

In ALL cases: The application has been lodged after field work, lab work, interviews, or other substantive research (excluding the research proposal) have been carried out. Some research is exempt from ethics clearance. Refer to Chapter 5 ETHICS IN RESEARCH FAQS, 7.1.4 Eligibility for exemption from review? Researchers should contact their departmental representatives or the Chair, if they are in doubt of the exemption. Some research may be approved by expedited review. Expedited review means that the full review process may be completed by a shortened process so that the time from submission of the application to decision is reduced, e.g. where the research appears to expose participants to no more than minimal risk of harm. The normal application form must be completed and a motivation for expedited review submitted. The decision to expedite ethics clearance is made by the EiRC. See FAQ Expedited review what is? Research involving children is not eligible for expedited review. The principal researcher has primary responsibility for determining whether the proposed research might expose participants to no more than minimal risk of harm. Possible harm includes foreseeable physical, legal, psychological or social harm, including emotional discomfort and stigmatisation. In making this determination, the researcher may seek advice from the EiRC. Sometimes disbursement of funding to support research or the granting of permission by an authority (e.g. government department) is dependent upon ethics clearance for the proposed research. The timing of these various processes can be complicated which means that applications for ethics clearance must be submitted with such time constraints in mind. When tendering for a research contract, it may be advisable that the ethics clearance application is submitted at the same time that the tender is put in to speed things up. In the case where follow-up research is intended i.e. the application is similar to others previously cleared, the expedited review process is likely to be followed. Students conduct research under the supervision of a member of the Faculty, who must approve the academic merit of the proposal before it is submitted to the EiRC for ethics clearance. Students and staff must therefore anticipate the amount of time needed for this step to be completed. Masters and PhD students should complete an application for ethics clearance under the supervisor s guidance. By signing off on an application for ethics clearance, a supervisor takes responsibility for supervising the student(s) in compiling the content of the application. The researcher has the obligation to inform the committee of any adverse events in order to assist researchers in clarifying if a project should be put on hold or ended. This is particularly important for any adverse events which put the researcher or participant at risk of any harm (e.g. bodily or psychological harm). Exemptions Expedited reviews Risk of harm Funding / research contracts Follow up Research Timelines for students Responsibility of supervisor Adverse events 13 P age

3 APPLICATION FOR ETHICS CLEARANCE If research is making use of human subjects, the researcher has to ensure that the proposal includes a discussion of the ethical issues involved in the proposed research and the measures that will be taken to deal with any negative implications. The researcher must consider each of the points/questions raised below, identify all potential issues, and address each in detail. Please note: The application must address all of the points raised below. It is important that researchers read the UCT Code for Research Involving Human Subjects and the Faculty of Commerce Ethics Guidelines. Research involving human subjects Applications must be accompanied by a research proposal (this may not be more than 15 pages). The methodological section of the proposal needs to be complete. It is impossible to discuss ethical issues without a detailed methodology (including research design and research methods). The following must be included in the research proposal: 1. A description of the proposed research highlighting its aims and objectives. This must include a brief summary of the purpose of the research, using non-technical language, a statement of the research problem and how the project will address it. 2. The research methodology, including research design and an explanation of the methods to be used (note that point 6 below asks more detailed questions regarding the sample, recruitment and research methods). 3. An outline of the prior experience the researcher and supervisor have in relation to the type of research, the research topic or the research area. The experience with the research and/or the population should be clarified. Assistants who will work with the researcher should be declared and their experience cited. 4. Specify the various types of information that will be collected in the course of the research. For example, personal and social information directly from participants, identifiable information about people from available records,? anonymous information from available records Or literature, documents or archival material on individuals or groups? 5. Specify how the research will be explained to participants and their informed consent obtained (this includes acquiring consent from relevant institutions). Attach copies of information sheet, consent form or script to be used for verbal consent (see exemplar in Appendix D). If participants are minors or otherwise lack capacity to consent to participation, indicate the source of permission (surrogate consent) and the method of obtaining assent from the participants. How will it be made clear to participants that they will participate in research and that they may withdraw at any time without reason? 6. How will you select and recruit research subjects, what methods will you use to engage with and obtain information from them, and what research tools will be used? (a) How and where are participants recruited? Will they participate voluntarily or be selected? Explain how they will be selected and/or who will be asked to volunteer. Indicate whether inducement is offered. (Attach a copy of letter, poster or advertisement, if any.) Justify the involvement of vulnerable groups. (b) Provide details of the salient characteristics of participants the number of participants, age range, gender, institutional affiliations and other special criteria. Describe the factors that may increase the vulnerability of participants Research proposal Research method Data to be collected Informed consent Research participants 14 P age

or increase their susceptibility to harm e.g. legal or social marginalisation, members of hierarchical systems, etc. (c) Describe how permission has been or will be obtained from co-operating institution(s) e.g. government department, school, hospital, corporation, prison, or other relevant organization (attach letters). Is approval of another EiRC required? If no permission is needed, that should also be clarified in the application. (d) Indicate what is required of participants and what information is gathered. (Attach copies of instructions, tests, questionnaires or interview guides to be used. If these are not yet designed, then final approval cannot be granted now.) How many times will observations, interviews, tests, etc. be conducted with one participant? How long will participation take? Are interviews tape- or video recorded? 7. How will confidentiality and anonymity be ensured? At what stage will identifiers be removed from data? If data must remain linked (i.e. identifiers retained), please explain why. 8. Will the research participants be deliberately deceived in any way? If so, what is the nature of the deception? Is it likely to be significant to the participants? Is there any other way to conduct the research without using deception? If so, why have you elected to use deception? How will you explain to participants after the research project is completed that they were deceived? 9. What will be done with the research data on completion of the proposed research? Will research data (written or otherwise recorded) be destroyed at the end of the project? If not, where and in what format and for how long will they be stored? To what uses research, demonstration, public dissemination, archiving might they be put in future? How will participants permission for further use of their data be obtained? 10. Explain in detail any potential harm that could befall the participants as a result of their participation in the research, specifically how you propose to avoid, counteract or ameliorate this harm. Describe the possible harms physical, psychological, legal, professional, and/or social. Are the risks of harm necessary? What measures will be taken to minimise the risk of harm? In the event that harm materialises, what are your plans for addressing the problem? (e.g. training for assistants, referral for counselling etc.). If risk of harm is anticipated to be no more than minimal, please state this here and in consent form. 11. What are the benefits of the proposed research for participants? How will participation in this research benefit participants? If participants will be debriefed or receive feedback information about the research after the project s conclusion, how will you ensure the educative value of the process? (Include copies of debriefing or educational materials). 12. Is the research done in a different country? What are the requirements in the country regarding ethics approval and research? Can private or confidential information about individuals be used in a research project? Has this information be sought out and clarified? Confidentiality and anonymity Use and protection of research data Risk of harm Benefits for participants International Research 15 P age

4 EXEMPLAR OF INFORMED CONSENT DOCUMENT [Heading] INFORMATION SHEET & CONSENT FORM [name target group] [Title of research project] [Greeting/Introduction] - e.g.: Hello, my name is...and I am conducting research towards a doctoral degree.] I am researching [brief essentials of project] and would like to invite you to participate in the project. [Subheading] - What the project is about [Explanation] - Briefly and in plain language explain the purpose of the research e.g., I am interested in finding out about... I want to understand how... I would like to interview people who... [Clarify that participation is voluntary] - e.g., please understand that you do not have to participate, ie your participation is voluntary. The choice to participate is yours alone. If you choose not to participate, there will be no negative consequence. If you choose to participate, but wish to withdraw at any time, you will be free to do so without negative consequence. However, I would be grateful if you would assist me by allowing me to interview you. [Explain what is expected of participants] - Explain what participant would be asked to do; how much time; whether any costs (e.g. transport) involved; whether any payment/reimbursement available, etc. Note if recording of interview is intended, request permission specifically in document for this. [Explain whether there will be any direct benefits to participant] note that there hardly ever is. [Explain the risk of harm to participants] - Explain what risk of harm might ensue, participants should have a reasonable idea about consequences of participation, e.g. discomfort, emotional upset, stigmatisation etc. [Anonymity and Confidentiality] - Explain whether/how anonymity will be preserved; how confidentiality will be maintained note if focus groups are intended, there is a builtin weakness with regards to confidentiality [Sharing and use of data] - Explain what will happen with data, whether/how any feedback to participants is possible note that you should try to do this to make participation meaningful Should you want supplemental information of the kinds of issues that could be considered, see http://www.who.int/rpc/research_ethics/informed_consent/en/, but please note that the exemplar above should be sufficient in most instances. Name of participant Date Signature of participant 16 P age

5 ETHICS IN RESEARCH FAQS This document is intended as a living document that can be added to or changed as queries or issues arise. If your question does not appear below, please contact the administrator of the Commerce EiRC. There are three sections Administrative matters, Substantive matters, and Ethics matters. 5.1 Administrative matters 5.1.1 Clearance from more than one EiRC? For example, Commerce students propose to use MBChB students as participants to test their understanding of human rights. Is ethics clearance from Commerce EiRC sufficient? No, you have to seek approval from Health Sciences and in addition to ethics clearance, permission to recruit students and/or staff members as research participants is required. Refer to 7.2.11 Use of UCT students or staff members as participants. If you are unsure if you require ethics approval from another committee contact your Departmental EiRC representative or the Chair of the Commerce EiRC. 5.1.2 Do students academic research projects require EiRC approval? Yes, if the research involves human participants, ethics clearance is required. Each project must have a supervisor who must oversee the completion of the documentation. Undergraduate students receive final clearance from their Departmental EiRC representative (as the HOD s nominee). For explanation of what defines a research project please refer to Section 2.10. 5.1.3 What is expedited review? When a research proposal appears to offer no more than minimal risk of harm to human participants, it may be eligible for review and clearance outside of the regular meeting schedule of the EiRC. This kind of review is called expedited review. Researchers who believe their planned research falls into this category should contact the administrator of the Commerce EiRC. Research involving children is not eligible for expedited review. 5.1.4 Eligibility for exemption from review? When there are no human participants, or when the review and analysis is of information freely available in the public domain (e.g. newspaper reports, meta-analysis of published work, etc.) or when institutional audits are undertaken (provided anonymity is maintained), then research is exempt from ethics clearance. Secondary data analysis is exempted from ethics clearance if the data: 1. Is a macro dataset (i.e. datasets that are purely about aggregates or are not about people, e.g. price data) 2. Is a re-analysis of micro-data derived from a recognised data service (this includes data sets which are recognised by the Data Seal of Approval http://www.datasealofapproval.org/en/, which has a list of trusted repositories 17 Page

including DataFirst). 3. is based on a data set that had received ethics approval prior to collection (e.g. StatsSA) Re-analysis of micro-data sets that are not obtained in this way, including administrative datasets and surveys with uncertain provenance would not form part of this exemption. For this type of data the Chair of Ethics should be informed in writing that such research is being planned and that, in the opinion of the lead researcher/pi, it meets the criteria for exemption. A brief outline of the research should be included with the letter. 5.1.5 Ethics review application process is so onerous. Not really if the application is complete and properly explained, there is usually no delay in being able to grant approval. The EiRC does its best to turn applications around as fast as possible. Only rarely is a proposal rejected. In general, queries or requests for substantive detail arise when an application is incomplete or when the researcher has not demonstrated that he or she has considered the ethical implications of the chosen methodology or procedures or particular population. 5.1.6 What is the role of the EiRC s? The EiRC is tasked with facilitating the highest ethical standards in research conducted under the auspices of the Faculty of Commerce. The members are required to have research ethics training and expertise in a variety of research methodologies. The EiRC s first role is as a research ethics clearing committee that reviews and grants ethics clearance for research that proposes to use human participants as sources of data. The objective is not to delay or prevent research but rather to facilitate high quality research, to ensure adequate protection of participants and researchers, as well as the institution. Engaging with this form of peer review process is part of the enterprise to make us better researchers and to facilitate and sustain excellence in research endeavours. The EiRC also has an educative role in the Faculty regarding research ethics training and consultations. Researchers are encouraged to consult with a member of the EiRC before submitting a proposal, especially when in doubt about particular aspects. The application process seeks to prompt researchers to consider all the necessary aspects for ethical research when drawing up a research proposal. 5.1.7 Where do I get the EiR application forms? For any research project with more then 90 credits or research projects done by staff members, applications do not require forms any longer. The application should be done through the online system, which can be found here: http://www.commerce.uct.ac.za/pages/ethics-in-research Detailed submission instructions are provided on the site. For applications which are signed off at departmental level, the departmental EiRC representative should be contacted for the necessary forms. 5.1.8 Why is ethics clearance necessary? Ethics clearance is necessary for legal and moral reasons. The Constitution protects bodily and psychological integrity. The National Health Act requires that all research involving human participants undergoes ethics review. The 18 Page

ethics review also ensures that researchers are made aware of potential ethical challenges they and their participants might be facing. 5.1.9 What about research in other countries? Research in other countries, which involves human participation may require in addition to the approval from the Commerce EiRC, in country approval. A useful resource is the following website: http://www.hhs.gov/ohrp/international/index.html as well as http://www.hhs.gov/ohrp/international/compilation-human-researchstandards/index.html It is therefore of utmost importance that the researcher familiarises him/herself with any national ethics requirements as well as organisational requirements which may differ from country to country. Since these requirements are often very case specific, it is useful to contact the departmental representative or the Chair of the EiRC. 5.1.10 What about research in other organisations? The researcher has to familiarise him/herself with the organisational requirements for accessing staff. It is important to show to the committee that the researcher has done that and that approval for accessing staff has been granted. 5.1.11 My research changed - do I need to reapply for ethical clearance? The researcher has to notify the EiRC immediately should any aspect of the study regarding the engagement with participants change. This may include aspects such as changes to the research design, questionnaires or choice of participants. An email should be sent to the EiRC administrator to highlight that a change has taken place. Depending on the impact of the change, the existing application can be updated rather than submitting a new application. 5.1.12 Human Sciences Research Council website Additional assistance is available at http://www.hsrc.ac.za in the HSRC Code of Research Ethics which is organized on the basis of four principles: the principle of respect and protection; the principle of transparency; the principle of scientific and academic professionalism; and the principle of accountability. 5.2 Substantive matters 5.2.1 What is minimal harm? Minimal harm is usually defined as no more than the risk of harm experienced day to day and routinely. In health care this could be viewed as routine medical, dental, psychological investigations and for other contexts, routine educational activities, etc. The idea is to give the potential participant some indication of whether there is an anticipated risk of harm and if so what sort might be expected and whether it is unusual, etc. 5.2.2 Access to government departments or NGOs? In addition to ethics clearance, access must be negotiated with the department or NGO concerned for permission to access documentation or personnel. Documents that are in the public domain do not require such permission. The department or NGO is entitled to review and approve (or not) the proposed research. To that end, the researcher must supply a clear and explicit explanation of the nature, purpose and intent of the research, including the aims, objectives, methodology, destiny of the findings, etc. In short, the 19 Page

research proposal should be submitted. This process is separate from the ethics clearance process. Usually, it is advantageous to have ethics clearance before submitting the proposal to the department or NGO. 5.2.3 Can EiR ethics approval be shared with colleagues working on similar projects? No. Approval is specific to particular researchers. 5.2.4 Can student research involve collecting personal data from other students? If the informed consent process is satisfactory, confidentiality is adequately protected and EiRC approval is granted, then this can happen. But such research should be discouraged when data are collected from peers or from students in the class of a researcher because of the potential for difficulties inherent in revealing personal information to peers and undue pressure. 5.2.5 What is deceptive research? This occurs when good research outcomes are unlikely if the participants know what is really being investigated because they are highly likely to adapt their behaviour or responses, etc. The research design will therefore include information (also in the informed consent documentation) that is not false but does not tell the whole story. It is usually expected that at the end of the research there should be a debriefing if possible to tell the participants that there was some deception, explain why and thank for their helpful participation, etc. See also Covert research in this FAQ. 5.2.6 Covert research Covert research, i.e. research that is conducted without participants knowledge or informed consent, should be avoided as far as possible because it breaches the rights and interests of human research participants in a blatant and fundamental manner. Nevertheless, in exceptional circumstances, it is possible that gathering particular data is so important and potentially valuable that this consideration outweighs the interests of the participants. In such cases, it is possible that covert methodology may be approved. The research proposal must justify and explain fully why a design using deception or covert research is desirable. The explanation must put the EiRC in the position to evaluate whether the design is justifiable. For example, it may be thought that obtaining informed consent is practically difficult or nearly impossible. The justification would have to demonstrate that the benefit from the research outweighs the nature and risk of harm to participants caused by the deception. The justification would also have to describe how participants would be harmed if they were to give informed consent; what the risk of harm would be; what risk of harm might exist for the researcher if informed consent is requested. The proposal must also describe how the participants will be debriefed after the period of research and how the researcher will deal with the possibly negative reaction from participants who feel aggrieved at having been deceived. 5.2.7 Ethnographic research Many researchers complain that the format of the application form precludes adequate description of planned ethnographic research insofar as the form seems to demand a hypothesis. 20 P age

On the understanding that the primary data-gathering tool for ethnographers is the relationships forged with the people whose life world is being studied, the description of the research would describe the design and the methods by which their life world is anticipated to be explored and analysed. Thus, it may be that the researcher will observe, tape-record, take notes, take pictures, ask various sorts of questions (many unknown at the start of the research, etc.) From the point of view of the EiRC, the description should include a discussion on how the individual interests of the persons under study would be protected. This discussion should be sufficiently detailed to allow the EiRC to understand what is intended and how ethical obligations will be met. Are systemic harms likely to arise from the findings of the project? How will data be analysed? Is there a theoretical model? Will the community know the research is occurring? I.e., will the researcher infiltrate the community or be there with permission and full co-operation of at least the leadership of the community? Will individuals give permission for tape-recording or photography? Will the researcher explain the destiny of the photographs? If publication is intended, how will the privacy interest of the individual be protected? What measures to protect confidentiality will be in place? Will the findings be made known to the community? Regarding risks of harm and likelihood of possible direct benefit for individual participants, it may be difficult to anticipate these in detail. However, if the purpose of the study is to understand relationships that involve potentially embarrassing or illegal activities, especially in relation to children, the researcher has an obligation to anticipate how these might be dealt with in the event of their occurrence. For example, there is a legal obligation to report child and sexual abuse. Consequently, no matter what the methodology, the researcher must have a plan as to how this obligation will be met or dealt with in the course of the research. Note also that harm can include wrongs; i.e. a person may not be harmed by the research but may nevertheless be wronged. Wrongs should be avoided and harms must be minimised. 5.2.8 Is ethics clearance required if the research only involves counting students at lunch time on Jammie steps? If the research involves only observation of public behaviour where the data are recorded so that no identification of the members of the public is possible (directly or via identifiers), then ethics clearance is not required. However, when in doubt, contact the EiRC for confirmation. 5.2.9 Preliminary work or pilot study Must preliminary work undergo ethics review prior to being undertaken? In general terms, preliminary work during which a literature review, tentative research plans and contacts with possible participants are made, does not require ethics review. For example, certain disciplines might speak to informants in the preparation phase of putting a proposal together and then use these data to inform the structure of the research project. If in doubt, please consult with a member of the EiRC. A pilot study, on the other hand, may need more careful consideration and review if it could be seen as an independent piece of work that may or not lead to a more extensive research project. 5.2.10 Publication of research findings The findings of a research project, including any limitations, should be reported and subjected to peer review and public scrutiny, i.e in a journal 21 P age

article or like publication. It is important, therefore, to ascertain before research is started that there are no obstacles to publication. For example, where permission to conduct the research is required from a state organ, the permission should include reasonable publication of the findings. If the data or findings are subject to an embargo, this should be made known in the proposal and some effort should be made to try to minimise the embargo. In reporting findings, adherence to the principles of honest, clarity, comprehensiveness and accountability is required. 5.2.11 Use of UCT students or staff members as participants? In addition to ethics clearance for the specific project, permission to access UCT student or staff information is required. For students, permission must be sought from the Executive Director: Student Affairs to access students and from the Executive Director: Human Resource for staff members. Thus, ethics clearance and permission for access are separate but interdependent processes. 5.2.12 What constitutes research? A systematic investigation designed to develop or to contribute to generalisable knowledge and conducted by means of surveys, interviews, focus groups, ethnographic observations, record reviews, etc. In the case of courses that require data from organization; if the collection of information is 1) not done to develop or to contribute to generalizable knowledge ; and 2) the output is an assignment/report written solely for the eyes of the lecturer, and which is marked as an assignment/learning assessment. It does not lead to a research output i.e. publication in the public domain. On these points it would not constitute research per se. However, if the information is going to a publication in the public domain or anything along that line, you will need ethics approval. 5.2.13 What is risk of harm? Harm can be physical, social or psychological, amongst others. Harm may flow from leaks in confidentiality, stress to participants, stigmatisation or by a participant making a statement that can upset superiors etc. 5.3 Ethical Matters 5.3.1 Conflict of interest within the EiRC In accordance with the UCT Conflicts of Interest: Principles, Policy and Rules document (at http://www.uct.ac.za/downloads/uct.ac.za/about/policies/conflictsofinterest.pdf ) the following fundamental principles and requirements serve as guidelines in dealing with conflict of interest issues. Committee members have a fiduciary responsibility to serve the interests of the university and of the public generally. All decisions are to be made solely on the basis of a desire to promote the best interests of the university and the public. Complete integrity of approach and of fairness in procedures is essential. The principles should not just be observed but should be seen to be observed. In many instances, perceptions play an important role in creating the impression of the existence of a dubious conflict of interest. The university s integrity is to be protected at all times. 22 P age